Office for Nuclear Regulation

EDF Energy Nuclear Generation Limited – Inspection ID: 52911

Date(s) of inspection:

  • November 2023

Executive summary

Aim of inspection

The aim of the inspection was, firstly, to assess the implementation of interface arrangements by the nuclear site licence companies – EDF Energy Nuclear Generation Limited (NGL) (Nuclear Operations), NNB GenCo – Hinkley Point C and Sizewell C Ltd (as a prospective licensee), covering interface, oversight and control of work conducted by Nuclear Services.

The second aim of the inspection was to gain confidence in the robustness of the arrangements and to understand forward plans for implementation of the next phase of Nuclear Services, formerly Technical Client Organisation/Technical Services Organisation (TCO/TSO), as it becomes a standalone organisation, jointly owned by the licensees it supports. This inspection is being conducted ahead of enacting the change.

This inspection was conducted jointly by safety and security inspectors regulating EDF Energy NGL, NNB GenCo – HPC and Sizewell C Ltd, enabling efficient and effective engagement, incorporating a cross purpose assessment. We are inspecting the licensees and prospective licensee’s ability to maintain control of their Nuclear Baseline and implement effective Intelligent Customer (IC) arrangements to deliver work activities through the TCO/TSO arrangements, as we regulate the licensees.

Subject(s) of inspection

  • LC17 – Management systems – Rating: Not rated
  • LC36 – Organisational capability – Rating: Not rated

Key findings, inspector’s opinions and reasons for judgement made

The inspection found that:

  • There are no significant shortfalls in current arrangements for oversight and control of work conducted by Nuclear Services on behalf of the licensees.  This takes into account that there are a range of existing regulatory issues and associated improvement plans in place to address safety and security shortfalls.
  • The arrangements for control and oversight of Nuclear Services are not yet sufficiently robust for implementation of the next phase of development of Nuclear Services.

ONR has provided written advice on its expectations for the arrangements that should be in place for the next phase of development of Nuclear Services. This covers aspects such as the need for a clear strategy and plan, clear governance and oversight arrangements and more robust management arrangements within Nuclear Services.

Conclusion

There are no significant shortfalls in current arrangements for oversight and control of work conducted by Nuclear Services on behalf of the licensees.  However, these arrangements are not yet sufficiently robust for implementation of the next phase of development of Nuclear Services.  ONR has provided written advice on its expectations for what these arrangements should achieve in the next phase.  ONR did not rate this inspection due to the wide-ranging scope and the number of licensees involved, taking into account as well the developing nature of Nuclear Services.